THE ACCIDENTAL ENTREPRENEUR PART V video
THE ACCIDENTAL ENTREPRENEUR PART V Podcast
Though the employer shared responsibility provisions of the Patient Protection and Affordable Care Act (PPACA) do not apply to small employers (generally, employers with fewer than 50 full-time equivalent employees), many...more
In a previous post, we reported on the Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization which reversed Roe v. Wade, and renders a woman’s right to make decisions regarding, and seek medical treatment...more
As we previously reported, on June 13, the Departments of Health and Human Services, Labor, and the Treasury (collectively, the “Departments”) issued a coordinated set of final regulations (“final rules”) permitting employers...more
On September 30th, the IRS issued proposed regulations that establish safe harbors for compliance with the employer mandate in the context of individual coverage health reimbursement arrangements (or “ICHRAs”). These proposed...more
As reported in our November 7, 2018 SW Benefits Blog Zombie Benefits – Are Health Reimbursement Arrangements (“HRAs”) Back From the Dead?, the Departments of Health and Human Services, Labor, and Treasury (the “Agencies”)...more
The Departments of Labor, Treasury, and Health and Human Services have released final rules removing the prohibition on pairing HRAs with individual health policies. The final rules also allow certain HRAs and other...more
As part of our ongoing series on the final regulations expanding the availability of health reimbursement accounts (“HRAs”), we discussed the newly-created Individual Coverage HRAs, which generally allow for employers to...more
Starting in 2020, employers will be able to offer health reimbursement arrangements (HRAs) that work in conjunction with individual coverage or Medicare without running afoul of the Affordable Care Act’s (ACA) market reform...more
On June 13, the Departments of Labor, Treasury and Health and Human Services jointly released final regulations dealing with health reimbursement accounts (“HRAs”). These regulations fulfill the Trump administration’s...more
On June 13, 2019, the Department of Health and Human Services (HHS), the Department of Labor (DOL), the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) (collectively, the “Departments”)...more
One potentially unintended consequence of the Affordable Care Act (ACA) was the demise of the average health reimbursement account (HRA). Such benefits were seen to violate the ACA prohibitions on annual and lifetime limits,...more
Effective January 1, 2020, employers may put aside pre-tax funds into a health reimbursement arrangement (“HRA”) that can be used by an employee to pay for premiums and other out-of-pocket costs related to the purchase of an...more
As discussed in our June 18th blog entry, the Departments of Labor, Health and Human Services, and Treasury (collectively, the “Departments”) recently released final regulations expanding the use of health reimbursement...more
On October 22, 2018, in perhaps the most significant guidance resulting from President Trump’s 2017 Executive Order 13813, “Promoting Healthcare Choice and Competition Across the United States” (“2017 Executive Order”), the...more
In October 2018, the Departments of Treasury, Labor, and Health and Human Services issued proposed regulations expanding the availability of Health Reimbursement Arrangements (HRAs) by eliminating a prohibition on integrating...more
Health Reimbursement Arrangements (or “HRAs”) are employer-funded, account-based group health plans, which are used to reimburse certain medical expenses incurred by eligible employees, their spouses, and their dependents....more
Takeaway Message: Except in limited circumstances, current regulatory guidance prohibits an employer from maintaining a health reimbursement arrangement (HRA) that reimburses the cost of premiums for individual health...more
The Affordable Care Act (“ACA”) has not been kind to health reimbursement arrangements (“HRAs”). Many employers got rid of HRAs, or integrated them with a major medical plan, in order to avoid significant penalties under the...more
Under a proposed rule that the Department of Labor (DOL), Department of the Treasury, and the Department of Health and Human Services (HHS) jointly issued on October 29, 2018, employers may soon have more flexibility to fund...more
Proposed IRS and DOL regulations have been issued expanding permitted uses for health reimbursement arrangements (HRAs). These proposals follow recent regulations on association health plans, both stemming from President...more
After a brief hiatus, Proskauer's ERISA Newsletter is back with a brand new look. We hope you like it and find it is easier to navigate. In addition to implementing our new format, we have moved to a quarterly publication...more
On February 27, 2017, the Internal Revenue Service issued Notice 2017-20 delaying the notice requirement for qualified small employer health reimbursement arrangements (“QSEHRAs”). By way of background, prior to enactment of...more
The impact of the Affordable Care Act (“ACA”) on health reimbursement arrangements (“HRAs”) has not been favorable. Many employers got rid of their HRAs or integrated them with a major medical plan in order to avoid...more
On December 13, 2016, the 21st Century Cures Act (the Act) was signed into law. It allows small employers to offer stand-alone qualified small employer health reimbursement arrangements (QSEHRAs) to employees who have...more
New Relief for Small Employer Health Reimbursement Arrangements - As mentioned in prior advisories, the Departments of Labor, Health and Human Services and Treasury have taken the position that employers cannot reimburse...more